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Issues: Whether the imported image intensifier system with ceiling suspension, adapter plate, specially designed video camera and monitor was classifiable under Heading 90.22 or under Heading 85.21, and whether the same classification applied for countervailing duty purposes under the Central Excise Tariff.
Analysis: The equipment was found to be a specialised medical system made up of distinct assemblies designed to work only with X-ray apparatus. The image intensifier accepted only X-ray inputs, converted the intensified image through an inbuilt specially designed camera, and transmitted it to the monitor for real-time use in operation theatres. It was therefore not treated as a general-purpose closed circuit television system, but as sophisticated medical equipment with dedicated use. The earlier tribunal decisions on similar systems were followed, where such equipment had been classified under Heading 90.22 rather than Heading 85.21.
Conclusion: The goods were rightly classifiable under Heading 90.22 and not under Heading 85.21, including for countervailing duty purposes.
Final Conclusion: The classification adopted by the lower authority was set aside and the appeal succeeded with consequential relief.
Ratio Decidendi: A specialised image intensifier and television system designed exclusively to function with X-ray equipment is classifiable as medical equipment under Heading 90.22 and not as a general closed circuit television system under Heading 85.21.